ML20206N730

Notice of Violation from Insp on 860701-31

ML20206N730
Person / Time
Site:	Byron
Issue date:	08/15/1986
From:	Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206N715	List: IR 05000454/1986025 ML20206N711 ML20206N730
References
50-454-86-25, NUDOCS 8608260369
Download: ML20206N730 (3)

Text

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4 NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-454 As a result of the inspection conducted on July 1 - July 31, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the following violations were identified:

1. ANSI NI8.7-1976/ANS-3.2, " Quality Assurance for the Operational Phase of Nuclear Power Plants," is endorsed by Regulatory Guide 1.33, Revision 2.

Regulatory Guide 1.33, Revision 2 is committed to in Appendix A of the Byron FSAR. ANSI N18.7-1976/ANS-3.2, Section 5.2.7 requires that modifications which may affect the functioning of safety-related structures, systems, or components shall be performed in a manner to ensure quality at least equivalent to that specified in the original design bases and requirements. Section 5.2.19.3 requires that tests shall be performed following plant modifications to confirm that the modifications reasonably produce expected results and that the change does not reduce safety of operations. Section 5.2.7 requires that design activities associated with modifications to safety-related structures, systems, or components shall be accomplished in accordance with ANSI N45.2.11-1974.

ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants," Section 6.3.3 requires that qualification testing shall be performed in accordance with written test procedures which incorporate or reference the requirements or acceptance limits contained in applicable design documents and that the test results shall be documented and evaluated to assure that the test requirements have been met.

Contrary to the above:

a. On August 27, 1985, December 13, 1985, and February 6, 1986 post-modification test procedures SPP 85-76,85-111, and 86-18 were approved for performance, and were performed, without any written acceptance criteria specified to verify the performance of the 150059 valves and 1TS-SD054 temperature switches.

b. On February 7,1986 the post-test review of post-modification test SPP 86-18 was completed without a written evaluation of the test results of Sections 1, 2, 3, and 4 of the test procedure.

This is a Severity Level V violation (Supplement I) (454/86025-01(DRP)).

2. Technical Specification 3.3.1, Table 3.3-1, Action Statement No. 2 requires that with a Power Range (PR) Nuclear Instrument (NI) channel inoperable that the respective bistables be placed in the tripped condition within six hours, while in Modes 1 and 2.

r600260369 860815 PDR ADOCK 05000454 0 PDR

Notice of Violation 2 Technical Specification 3.4.6.1, Action Statement c.3 requires that with the containment Atmosphere Particulate Radioactivity Monitor ~and the Containment Gaseous Radioactivity Monitor inoperable that a Reactor Coolant System (RCS) water inventory balance be performed once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while in Modes 1, 2, 3, and 4.

Technical Specification 3.3.1, Table 3.3-1, Functional Unit No. 6.b requires that two Source Range (SR) Nuclear Instrumentation channels be operable in Modes 3, 4, and 5 or else follow Action Statement No. 5.

Table 3.3-1, Action Statement No. 5 requires with both SR channels inoperable, within one hour, open the reactor trip breakers, verify valves ICV 1118, 1CV8428, 1CV8439, ICV 8435, and 1CV8441 are secured in the closed position, and suspend all operations involving positive reactivity changes.

Contrary to the above:

a. On June 30, 1986, while in Mode 1, from 1049 to 2245 with PR channel N41 inoperable, the high and low Neutron Flux protective trips and positive and negative Neutron Flux Rate High protective trips were not placed in the tripped condition for 11.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />; thereby exceeding the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time limit by 5.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />,

b. On June 4, 1986, while in Mode 1, with the Containment Atmosphere Particulate Radioactive Monitor and the Containment Gaseous Radioactive Monitor inoperable, the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit for performing the RCS water inventory balance was exceeded by 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

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c. On July 3, 1986, while in Mode 3, from 0140 to 1142 with both SR channels inoperable, valves ICV 1118, ICV 8428, 1CV8439, 1CV8435, and t ICV 8441 were not verified to be secured in the closed position within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; thereby exceeding the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit by 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.

d. On July 3, 1986, while in Mode 3, from 0910 to 1057 with both SR channels inoperable, positive reactivity was added to the core by

! cooling down the Reactor Coolant System from 557 to 535 F; thereby exceeding the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time limit by 0.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This is a Severity Level IV violation (Supplement I) (454/86025-02(DRP)).

With respect to item 1, the inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Consequently, no reply to the violation is required and we have no further questions regarding this matter. With respect to item 2, pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; l

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• Notice of Violation 3 (2) corrective action to be taken to avoid further violations; and (3) the date when full-compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

V/f//6 L Dated' R. F. Warnick, V ief "

Reactor Projects Branch 1

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